"Fire in a crowded theater" is an assertion that there are limits to protected speech. It says nothing about what those limits are. Harmful misinformation is well inside those limits. (And in any case it's from a decision that was overturned 50 years ago.)

For a somewhat snarky lawyer's explanation, see: https://www.popehat.com/2012/09/19/three-generations-of-a-ha...

I'm not confused on this matter I'm asserting it ought to change.

You said these things "have never been protected", and that "there have always been limits". Those are descriptive (and incorrect) statements about the actual law.

If you think the law is bad and should be different, say that. Don't phrase your policy goals as if they're the way the law currently works.